We are down to the wire for adoption and implementation of a customer identification program. There has been a lot of talk and more worry about what is or should be involved.
How does the new Patriot Act regarding CIP address closed accounts? What I mean is if a customer has closed an account but still is on our operating system with all information, are they considered a new customer if they come in to open a new account?
The CIP ruling did not specifically address the mortgage lenders. How can we or when should we identify customers on mail applications, telephone applications or when the loan is being handled by a representative with a power of attorney and the borrower cannot be present?
Our bank is going to start offering online loan applications for customers to print, fill out and send in for home mortgages. Do we have to give any disclosures out on the Web site to customers printing up a loan application? We will also be taking applications for new accounts online. To stay in compliance with the CIP regulation, will they have to come into the bank for the account to be opened? Do we have to have the disclosures online or can they be given to the customer when the customer comes into the branch?
Our bank accepts funds via wire transfer from a broker who places the funds with the bank on behalf of public school districts. The bank opens CDs with the funds in the name of the school district. What documentation will satisfy customer identification requirements?
For CIP, do we need to keep actual copies of documentation used to identify a business (for example, Articles of Incorporation)?
Regarding the TIN requirement of BSA 31 CFR 130.34, does it apply to the members of religious groups who do not have SSNs or TINs due to their beliefs? If they want to open an account, are they required to furnish a TIN? What if they don't have a TIN and they are an existing customer?
Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?